Taxes Management Act 1970 section 31

Appeals: right of appeal

Section 31 sets out the circumstances in which a taxpayer has the right to appeal against amendments or assessments made by HMRC.

• Taxpayers may appeal against amendments HMRC makes to a self-assessment during an enquiry to prevent loss of tax, or amendments and conclusions in closure notices issued when HMRC completes an enquiry into a personal, trustee or partnership return.
• Appeals may also be brought against HMRC amendments to partnership returns where a loss of tax has been discovered, and against any assessment to tax that is not a self-assessment.
• Where an appeal is made against an amendment to a self-assessment while an HMRC enquiry is still in progress on the same matter, the appeal process is paused — no further steps can be taken until HMRC issues either a partial or final closure notice.
• For simple assessments, the taxpayer cannot appeal until they have first raised a query with HMRC about the assessment and received a final response to that query.